Summary

The FCA has launched a Consumer Credit Market Review to examine concerns it has about the operation of the consumer credit market and the potential for consumer harm. They are primarily interested in;

  • The coverage and quality of credit information (CI)
  • The effectiveness of competition between Credit References Agencies (CRAs)
  • The extent of consumer engagement with CI

The purpose of this review is to inform the FCA’s understanding of the market to determine if further work is necessary.

Market Study Scope

Theme 1: Purpose, Quality and Accessibility of Credit Information

FCA has identified concerns about the coverage, timeliness and accessibility of credit information and the potential for consumer harm to arise from this. For instance, a lender may decide not to provide credit to an otherwise low risk consumer due to insufficient credit information with which to assess an applicant.

Furthermore, a lender may nonetheless proceed to supply credit (inefficient lending), which can cause over-lending, under-lending and over-pricing.

Theme 2: Market Structure, Business Models and Competition

In keeping with FCA’s strategic approach, their view is that CRAs should create strong incentives to ensure that good quality credit information and services are accessible and competitively priced.

However, FCA claim that some lenders have raised the issue of high monetary and operational costs for switching between CRAs, or for subscribing to multiple providers. FCA’s concern here is that some CRAs could be in positions of significant market power that could translate to consumer harm down the line.

Theme 3: How Credit Information and Services Affect Consumer Behaviour

The regulator will also determine whether poor consumer awareness about their credit ratings could be causing behaviour which negatively impacts their creditworthiness and their ability to improve it.

Theme 4: The Future Evolution of the Credit Information Market

The final theme of the study will examine the potential impact of new methods of data gathering and analysis and how these will change or impact the market. They could present opportunities for consumers to engage with their credit information, but it could also present new risks.

Credit Information Market Structure

FCA defines the credit information market’s structure as;

  • Credit Reference Agencies
  • Data Contributors
  • Credit Information Users
  • Credit Information Service Providers

Timeframe

Spring 2020 – Interim report setting out analysis, preliminary conclusions and preferential solutions to address identified concerns.

Late 2020 – The report states that findings will be published “later in 2020”